Review of Emergency Health Services at Orlando Regional Healthcare Furnished to Undocumented Aliens Covered by Section 1011 of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003

In our review of emergency health services that Orlando Regional Healthcare System, Inc. (ORH), furnished to undocumented aliens covered by section 1011 of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003, we found that the ORH received approximately $17,000 in unallowable payments for these services. The unallowable payments occurred because ORH did not always follow its own policies and procedures for ensuring that services were appropriate, medical records were sufficiently documented, and treatments were for emergency medical conditions. Furthermore, ORH's written policies and procedures did not address section 1011 requirements regarding reimbursements from third-party payers.

We recommended that ORH (1) refund approximately $17,000 received for services that did not meet section 1011 reimbursement requirements, (2) review the remaining claims for our audit period and claims for subsequent periods and submit adjustments for any claims that did not meet section 1011 reimbursement requirements, (3) follow its existing policies and procedures to ensure that future section 1011 program claims meet section 1011 reimbursement requirements, and (4) develop and implement procedures to ensure that reimbursements for services are made to the extent that a third-party payer did not otherwise reimburse care. ORH agreed with our recommendations.